European Union – Direct taxation. The proceedings concerned the decision of the French tax authorities, first, to re-assess the amount of unrealised capital gains relating to substantial shareholdings, in the capital of companies established in France, held by the taxpayer and which he had declared at the time of transferring his residence from his state of origin to Switzerland and; second, to make him liable for additional assessments to income tax and social security contributions, with penalties. In the course of those proceedings, the Court of Justice gave a preliminary ruling on the interpretation of the Agreement between the European Community and its Member States and the Swiss Confederation on the free movement of persons.